Building Smarter Climate Policy
We are a think tank conducting data-driven and evidence-based advocacy to improve climate policy in the EU and beyond.
Telling Peter Liese how the ETS can reduce aviation emissions
Sandbag discussed the EU ETS at a meeting of the AGE, an initiative of the German Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety
Sandbag presented its EU ETS amendments at German government event
Sandbag discussed the EU ETS at a meeting of the AGE, an initiative of the German Federal Ministry for the Environment, Climate Action, Nature Conservation and Nuclear Safety
EU ETS review: Response to the European Commission’s public consultation on the EU ETS review
Sandbag’s response to the public consultation on the European Commission’s review of the EU ETS COM(2026)620.
A guide to the EU CBAM – perspectives for Chinese stakeholders
This report reveals the implications of the EU’s CBAM for Chinese firms and outlines ways that Chinese firms can address relevant challenges.
Sandbag at Wopke Hoekstra’s CBAM Implementation Dialogue
On 15 October 2026, Sandbag’s Adrien Assous had the honour of participating in a CBAM Implementation Dialogue organised by Commissioner Wopke Hoekstra.
Discussing aviation at Carbon Forward Expo London 2026
On 14 October, Sandbag’s Adrien Assous moderated a panel at Carbon Forward Expo London 2026: “Is the EU ETS delivering on its objectives? Will the proposed reforms help or hinder progress?”
Webinar: Options for the EU ETS
We presented Sandbag’s analysis of different design options for the EU ETS, and discussed proposals to mitigate potential negative impacts.
EU ETS amendments: what matters
Our position paper analyses the proposals by the Commission and EU ETS rapporteur MEP Peter Liese and presents Sandbag’s proposals.
Putting a seat belt on allowance use: how aviation could do its part
This brief proposes that access by airlines to emission allowances from other sectors should gradually be reduced.
EU ETS review: impacts on the market balance
In this brief, we analyse how the proposed changes will impact the supply and demand balance of the emission allowance market.
Our Impact
September 2026: CBAM Extension Trilogues: Parliament mandate reflects key Sandbag recommendations
On 15 September 2026, the Parliament adopted a position on anti-circumvention rules which echo recommendations that Sandbag had been advocating for several years. The proposed text includes a definition of resource shuffling, the systematic ex-ante recourse to default values in case of high risk of abusive practices and a single default value for unwrought aluminium, regardless of it containing pre- or post-consumer scrap. Sandbag had flagged concerns about the scrap loophole as early as 2023, and recommended a more systematic recourse to default values.
Read the position paper (see p. 3-5).
September 2026: European Parliament voted to remove Article 27a from the CBAM
This is an achievement for Sandbag as it comes after our calculations and analysis on the CBAM and the drivers of fertiliser price increases was circulated extensively and quoted by MEP Mohammed Chahim, rapporteur for the CBAM at the European Parliament, who opposed the use of Article 27a.
Sandbag’s position paper on the Commission’s legislative proposal amending the CBAM had advocated for the deletion of Article 27a.
Read the position paper (see p. 3).
Read the amendment (see p. 44).
September 2026: European Parliament voted to reinstate the invalidation of allowances in the MSR
Sandbag had advocated against stopping MSR invalidation, highlighting the impact thereof on the carbon market’s supply/demand balance.
Read our analysis (see p. 3).
Read the amendment (see p. 4).
March 2026: European Court of Auditors cited Sandbag in its report on the Innovation Fund
Sandbag’s analysis was cited in the European Court of Auditor’s special report on the innovation fund, published on 23 March, 2026.
Citing Sandbag, the report notes that the rating system rewards over-optimistic estimates. As this methodology is used for two of the five award criteria, it is a serious structural flaw.
Read the report (see p. 30).
Our Work
EU ETS
We fight to make the EU Emissions Trading System more effective at driving the decarbonisation of industry, aviation and shipping.
CBAM
We advocate for a fast and comprehensive Carbon Border Adjustment Mechanism to replace the free allocation of emissions allowances under the EU ETS, which is a major flaw of the carbon market.
Industry
Designing policy instruments requires expertise on the sectors and technologies they cover. We have built expertise in steelmaking, aluminum, construction, hydrogen, electrification, and circularity.
Our Interactive Tools
The impacts of policy options are sometimes difficult to estimate, especially when several parameters can be combined. We publish visual tools and simulators to better understand policies and different combinations of policy design options.
Join us in building smarter climate policies!
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